Last Updated: April 7th, 2019
DEFINITION OF PERSONAL INFORMATION
We define the term “personal information” to mean any information that we directly associate with, or use to identify, a specific person. This may include information such as an address, phone number, email address, or fax number; a user name or other online registration information; a financial account or credit card number, and transaction information or purchase history, when associated with a person’s name. Personal information does not include “aggregated information,” which is information that we collect about a group or category of persons or services. It also does not include “de-identified information,” which is information from which we or our agents have removed any information that can be used to specifically identify a person. This policy does not restrict or limit our collection, use, or disclosure of aggregated or de-identified information.
COLLECTION OF INFORMATION
We may collect your personal and other information described below in various ways, including, but not limited to, the following:
Personal Information You Provide. We may request, or give you the opportunity to provide, personal information when you register as a user of our website or sign up for our programs, or take one of our surveys, use our products or services, cash a check, contact us about a prior purchase, or email, call, or otherwise communicate with us. Similarly, if you contact us regarding a product or service that you are interested in or concerned about, we may request that you provide personal information that will enable us to respond to your inquiry.
Automatically Collected Information. When you shop online, register for or use any of our online or other services, transactional and other information, such as the date of your purchase, registration, or service usage, their descriptions and, if applicable, the dollar amount or value of the transaction, your Internet protocol address, browser type, domain names, access times, operating systems, mouse clicks and movements, and scrolling activities may be collected automatically or “passively” by us or by one or more of our third party service providers. For example, we may use third-party analytics tools that collect information about use of our websites and user traffic. We treat this information as personal information if we combine it with or link it to other information that may identify you.
Other Information. We may obtain information about you from third parties such as demographic marketing information, address verification, or mailing list information and combine it with other personal information pertaining to you.
OUR USE OF PERSONAL INFORMATION We may use your personal information for a variety of purposes, including but not limited to:
- Responding to your requests or inquiries.
- Processing and completing your transactions including, as applicable, order confirmation, billing, enrollment in our programs, and delivering products or services.
- Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information.
- Contacting you about programs, products, or services that we believe may be of interest to you.
- Providing you with programs, promotional information, and offers.
- Conducting market research, surveys, and similar inquiries to help us understand trends and customer needs across product categories or customer groups.
- Analyzing transactions or purchase histories to present customized offers to you or to improve our products, services, programs, and other offerings.
- Keeping a record of our interactions with you if you place an order or otherwise deal with our representatives over the telephone or online.
- Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, our website or data systems; or to meet legal obligations.
DISCLOSURE OF PERSONAL INFORMATION We do not sell or rent your personal information to third parties in the ordinary course of our business, nor do we disclose to them the personal information we collect for their own direct marketing purposes. However, upon the occurrence of certain corporate transactions, we may disclose or transfer your personal information as described under the “Certain Business Transfers” section below. We may also share your personal information with our parent or affiliated companies for their use in a manner similar to the purposes described in the “Our Use of Personal Information” section above. Though not an exhaustive list, our most common practices with respect to the disclosure of personal information are described below.
With Your Consent. We may disclose your personal information to third parties with your consent. You may give your consent in several ways, such as through a written agreement that you sign or acknowledge; an online method, such as a “click through” agreement or registration page; through a mobile application which you install on your mobile device or by enrolling in a text alert program; an oral statement, such as by way of an interactive voice response; or through the terms and conditions under which we provide you a particular product, service, or program. Sometimes your consent may be implicit. For example, if you purchase products with a credit card and have them shipped to your home, you implicitly consent to the disclosure of your name and address to a third-party shipping company to complete the delivery, and of your credit card number to the credit card processor to authorize the transaction and to the bank to collect payment.
Service Providers. We may disclose your personal information to third parties who complete transactions or perform services on our behalf or for your benefit. Information provided to such parties for payment authorization or verification purposes may be retained by them in a database that is used to provide similar services to others. We may also utilize the services of third parties to verify customer data, such as mailing addresses or to supplement other information we have collected. We may also contract with third parties to host a site, conduct market research, or send you information regarding our products or services or those of other companies with whom we conduct business.
Legal Process. We may disclose your personal information to legal or government regulatory authorities in response to their requests for such information or to assist in investigations of theft, fraud or abuse. We may also disclose your personal information to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary in an emergency.
INFORMATION PERTAINING TO CHILDREN Our websites are not directed to, and we do not intend to, or knowingly, collect or solicit personal information online from children under the age of 13. We encourage parents or guardians to participate in and monitor their children’s online activity. If a child under 13 has provided personal information to us without parental or guardian consent, we encourage the child’s parent or guardian to contact us (see the “How to Contact Us” section below) to have the information removed from our systems. If you are under the age of 13, do not provide us with any personal information either directly, on any website bulletin boards, or by other means.
ACCESS TO AND RETENTION OF PERSONAL INFORMATION We do not maintain all of your personal information in a form that you can access or update, and some items, such as transaction records, may not be changed. Accordingly, we will determine and may limit what may be accessed and how, and we may keep a record of changes (including deletions) and disclose them for lawful purposes. We keep your personal information for as long as we think is necessary or advisable, and we reserve the right to retain it to the full extent not prohibited by law. You may review your personal information that is readily accessible or contact us to request that it be updated by contacting our us (see the “How to Contact Us” section below).
SECURITY OF PERSONAL INFORMATION We use various physical, electronic, and procedural measures designed to protect your personal information from unauthorized access, disclosure, or misuse. However, because no data security systems are completely secure, we do not warrant that any personal information that you provide to us will be secure or safe from unauthorized access. If you provide any personal information to us, you do so at your own risk.
OPT-OUT CHOICES We may send you email messages, direct mail offers, or other communications regarding products or services unless you specifically ask us not to do so when you access our websites or mobile applications, or change your preferences by updating any accounts you may have with us. At any time, you may elect to discontinue receiving commercial messages from us by submitting an opt-out request when applicable (see the “How to Contact Us” section below) or by following the instructions in the form of the communication you received, as described below. We will endeavor to process your opt-out request in a commercially reasonable time.
Printed Materials: To opt out of receiving printed marketing materials at your postal address, such as advertisements, flyers, newsletters or postcards, write to us at the address below. Please be sure to include your name and mailing address exactly as they appear on the printed marketing materials you received.
Emails: To opt out of receiving marketing materials via email, please send an unsubscribe request to the email address below or click on the unsubscribe link at the bottom of the email that was sent to you and follow the directions on the resulting web page.
Voice or Text Messages: To opt out of receiving calls from our live representatives by telephone, contact us at the address below.
Google Analytics: You may opt out of the aggregation and analysis of data collected about you on our website by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout and downloading and installing the Google Analytics Opt-out Browser Add-on.
DATA TRANSFERS We are based in the United States. When we obtain information about you, we may transfer, process, and store such information in the United States and other countries. By using our websites, you consent to the transfer to, and to the processing and storage of your information in, countries outside of your country of residence, which may have different data protection laws than those in the country in which you reside.